FY 2014 Conference Significant Item
Fiscal Year 2016 Superfund Budget
Worker Training Program – The Committees direct NIEHS to explore the feasibility of incorporating a nominal fee to recoup administrative or other costs associated with the Worker Training Program. NIEHS should include a report that summarizes findings and recommendations with the fiscal year 2016 budget request.
Action taken or to be taken
The National Institute of Environmental Health Sciences (NIEHS) Worker Training Program (WTP) is a long-standing initiative that provides job training to a population that includes underserved, low-income, and/or jobless individuals through a diverse set of grantee institutions, and does so efficiently with low overhead. The WTP is an umbrella consortium authorized by Section 126(g) of the Superfund Amendments and Reauthorization Act of 1986. The WTP consortium builds upon Federal-level partnerships that have been created over the last 20 years. The overhead costs for administration of the program continue to be at or below the levels of similarly situated federal cooperative agreement programs.
The National Institutes of Health (NIH) and NIEHS have taken a careful look at the program mission and objectives and have reviewed data from the grantees related to how they provide their services, as well as any income generated from their training programs. Given the program objectives, and in light of the characteristics of both the variety of grantee institutions and the trainee population served, NIEHS finds that it would be both administratively difficult and counterproductive to the mission of the program to attempt to impose a fee across the board for trainees to have access to the program offerings.
The diverse family of WTP programs includes the Hazardous Waste Worker (HWW) training program, the Environmental Careers training program, the Hazmat Disaster Preparedness training program, and the Hazmat Training Program for Nuclear Weapons Cleanup, which is administered through an Interagency Agreement with the U.S. Department of Energy (DOE). Also, grantee organizations come from many different places, including academic consortia developed at four-year universities; Historically Black Colleges and Universities; Community Colleges; industry-based colleges; non-profit organizations dealing with occupational health; joint labor management trust funds; labor-based unions; and other groups. Each of these groups of institutions uses different business models to run their programs and deliver training in a cost-effective way for their target populations. Charging training fees has always been an option, but not a program requirement. In FY 2010, for example, 3 out of 20 grantees generated program- related income (specifically, for the Hazardous Waste Worker training program).
A variety of approaches are incorporated into the training process to ensure an equitable public-private partnership in expending appropriated funds. For example, the Steelworkers Union generates program-related income by soliciting funds from employers to enhance the training provided. Some university groups also charge nominal fees depending on the target audience for the training. Some targeted groups, such as unemployed or disadvantaged persons, are not able to pay for training; thus, no charges are levied.
NIH policy, as stated in the NIH Grants Policy Statement (last revised, 2012), allows for program-generated income to be proposed by the applicant organization. Program income is defined as gross income, earned by a grantee, a consortium participant, or a contractor under a grant, that was generated directly by the grant-supported activity or earned as a result of the award. Program income includes, but is not limited to, income from fees for services performed; charges for the use or rental of real property; equipment or supplies acquired under the grant; the sale of commodities or items fabricated under an award; charges for research resources; registration fees for grant-supported conferences; and license fees and royalties on patents and copyrights. The grantees are permitted to utilize program income using the additive alternative, in which program generated income is added to funds committed to the project or program and used to advance eligible project or program objectives. The amount of program income earned and expended must be reported on the appropriate annual financial report. In the cases where income has been generated by the WTP, the funds generated have been used to buy supplies and equipment for training or for instructor and curricula development.
NIEHS has further reviewed existing Grants Management Policy for the Department of Health and Human Services (HHS) and NIH to inform any changes in our approach toward program income. This review included analysis of administrative costs associated with collecting, distributing, and using optimal processes for retaining fees from trainees, employers, or the organizations that provide the training through the retention of program income or other methods for revenue capture. A variety of challenges would be expected with the incorporation of a fee for recouping costs, which may limit the viability for some, if not all, grantees.
NIEHS considers that, given the wide variety of grantee institutions serving the WTP, the low income of most of the target populations, and the existing low overhead cap of the program, it would not be feasible to mandate a fee collection model across the board. However, that does not preclude individual grantee programs from choosing to take advantage of existing policy to enhance their offerings.
As NIEHS developed the recent Funding Opportunity Announcement (FOA) for soliciting and competing for new cooperative agreements for this program in FY 2015, we clarified the option under current policy for grantees to generate program-related income where appropriate. Specifically, in the Funding Opportunity Announcement (FOA) RFA-ES-14-008 (released on July 28, 2014), NIEHS WTP included language to encourage applicants to develop sources of program income to supplement the federal grant resources provided to support the development of model training programs in hazardous materials response. This is expected to provide enhanced program support for the future.